April 20, 2009 Susan Schechter, Chief American Community Survey Office Room 3K276, Mail Stop 7500 Washington, DC 20233-7500 Dear Ms. Schechter: The Mid-America Regional Council (MARC) is an association of local governments and the metropolitan planning organization (MPO) for the bi-state Kansas City metropolitan area. In its role as the MPO, and for a variety of other responsibilities and purposes, MARC relies on demographic and related data from the Census Bureau. We are very interested in the transition that the Census Bureau is making from the census long-form sample to the American Community Survey (ACS). However, we are very concerned with the detailed data that will be available through the ACS, as described in the March 6, 2009 Federal Register. According to prior information on the ACS that we’ve seen from the Census Bureau itself and from other federal agencies, we have been led to believe that the data available from the ACS would be at the “county, city, and neighborhood” level, and at the “detailed long-form level of geographic detail.” Based on statements such as these, we have been anticipating ACS data tabulations that would provide as much detail as prior Census products. However, the information discussed in the March 6 Federal Register notice, and particularly the restrictions on the release of data to meet disclosure requirements will seriously impact the amount of data actually available for smaller geographic area analysis. The limitation in small area data will make it much more difficult to address significant issues that are important for the country’s future progress, but which play out in decisions that must be made at a local level:

• Climate Change – to effectively address climate change, planners must have access to data that makes it possible to fully evaluate the relationship between land use patterns, demographic characteristics and transportation choices.

• Social Equity – to effectively address social equity, planners much understand the composition of the population in terms of disabilities or other mobility impairments, transit-dependent populations, households receiving temporary assistance for needy families (TANF), limited English proficiency, and environmental justice status (low incomes and minority population concentrations) and be able to relate those individuals and households to job opportunities, job access and reverse commute needs at a small geographic scale.

• Emergency Response – to ensure areas are well prepared for a range of possible emergency situations, planners must be able to identify populations that may require special assistance to evacuate or otherwise be protected from dangerous conditions, or for which communications may need to be tailored to ensure their understanding and appropriate actions in response.

600 Broadway, Suite 200Kan as ity, Missouri 64105-1659

16/474-4240816/421-7758 FAXwww.marc.org

Mid-America Regional Council

bail'Tom ooleComt11is ioner

n;f1ed GO\'emlllentof Wyandone County!Kansas Cily. Kan.

I t ice ChairJim cbultzCouncihnelllberIndependence, Mo.

2nd \ ice hail'Marge Vogt

ouncillllemberOlalhe. Kan,

TreasurerJim PlullkettCOlllllli ionerPlane County. Mo.

ecretaryJan Marca on

oUllcillllemberKansas City. 10.

Executive DireclorDavid A, Wal1u

• Effective Transportation – in an era of decreasing transportation funding, performance-based planning takes on greater urgency. To ensure that limited transportation resources are deployed as effectively as possible to support the nation’s economic activity, planners must have access to data that supports detailed analysis of a range of transportation options in the context of actual traveler behavior.

We are concerned that the proposed rules as detailed within the March 6, 2009 Federal Register will clearly and adversely affect the ability of our region to respond to these regional and national goals and objectives. We would encourage the Census Bureau to develop and consider additional, creative solutions that would provide data at the level of detail to support responsible planning and decision-making. In particular, we request that the Census Bureau make clear the level and cost of additional sampling to achieve the same levels of statistical reliability and data suppression as in the 2000 Census. We also request the Bureau investigate ways to use synthetic data techniques to provide the small area estimates needed without compromising data confidentiality, and report on the cost and quality of such estimates. Sincerely,

Mell Henderson Director of Transportation cc: Sen. Kit Bond, Missouri Sen. Sam Brownback, Kansas Sen. Claire McCaskill, Missouri Sen. Pat Roberts, Kansas Rep. Emanuel Cleaver II, MO-5 Rep. Sam Graves, MO-6 Rep. Lynn Jenkins, KS-2 Rep. Dennis Moore, KS-3 Rep. Ike Skelton, MO-4

April 16, 2009 Ms. Susan Schechter Chief American Community Survey U.S. Census Bureau Room 3K276 Mail Stop 7500 Washington, DC 20233-7500 RE: Federal Register notice of March 6, 2009, for the Notice of Solicitation for the

American Community Survey (ACS) 5-Year Data Products Dear Susan, This letter responds to the March 6, 2009, Federal Register notice requesting comments concerning the plans to 1) introduce 5-year data products in the ACS covering the period 2005 - 2009, and 2) modify the current line of data products to accommodate the 5-year data products. The Bureau of Economic Analysis’ (BEA) Regional divisions will benefit greatly from the release of the 5-year data estimates. The divisions are listed below with an explanation as to how these new estimates will improve BEA data quality. I. Regional Product Division

(Responsible for the gross domestic product (GDP) by state, GDP by metropolitan area, and regional economic multipliers.)

Reassessing BEA economic area (BEA EA) validity is one of the major items being undertaken by the Regional Product Division (RPD). Since 1969, BEA EAs have had four rounds of redefinitions since their initiation. RPD has relied primarily on the decennial censuses of county commuting data to revise the areas. The main linking variable in delineating the EAs was commuting of the labor force in each non-nodal county.

BEA EAs define the relevant regional markets surrounding metropolitan areas. Each EA consists of a central market area and surrounding counties that are economically related to the central area. The current set, redefined in 2004, has 179 areas.

BEA EAs are widely used in government and private sectors, such as the Federal Communications Commission’s use for regional airwaves licensing, the U.S. Department of Agriculture use for planning of forest and rural land uses, and the U.S. Department of Transportation’s use for analysis of freight transportation. Private and academic researchers, such as the National Bureau of Economic Research or

2

university think tanks, also use BEA EAs for regional economic growth and industry analyses.

Because of the elimination of the long form in Census 2010, BEA needs ACS 5-year averages of commuting data by county or county-equivalents to perform the task, even though they are surveyed data. With the availability of the 5-year estimates, one of the first of the revisions will include reexamining the economic node and non-nodal counties that were economically tied to the node. The nodes consist of cored based statistical areas identified by the Office of Management and Budget.

II. Regional Income Division

(Responsible for annual and quarterly estimates of state personal income, and annual estimates of personal income for local areas.)

The Regional Income Division will be using the 5-year county data from the American Community Survey to develop estimates of rental income from the housing questions in the ACS, and to adjust compensation from a place-of-work basis to a place-of-residence using journey-to-work and income data from the ACS. Specifically, the number of mobile homes and the aggregate value of owner occupied housing will be used in BEA’s county estimates of rental income; and information on the place of work, the industry of work, and the wages earned will be used to generate flows of income from the place-of-work to the place-of-residence so that BEA can produce a net adjustment for residence to put the income estimates on a place-of-residence concept.

At this time, the proposed products from the 5-year estimates appear adequate for BEA purposes. However, with the release and review of these estimates, we will be able to determine if our data needs are met. If you have any questions, please contact Ruth Bramblett, Source Data Coordinator, on 202-606-9653 or by e-mail at Ruth.Bramblett@bea.gov. Sincerely,

/s/ Dennis J. Fixler Chief Statistician

OKLAHOMA DEPARTMENT OF TRANSPORTATION200 N. E. 215t StreetOklahoma City, OK 73105-3204

April 17, 2009

Ms. Susan Schechter, ChiefAmerican Community Survey OfficeRoom 3K276, Mail Stop 7500Washington, D.C. 20233-7500

Dear Ms. Schechter:

The Oklahoma Department of Transportation's Planning & Research Division strongly opposesthe action proposed by the US Census Bureau as noted in the March 6, 2009 Federal Registerto revise the American Community Survey 5-year data planning products. I

The U.S. Census has long been a critical data source for transportation planning and relatedregional transportation investment. The American Community Survey (a new censuscomponent that replaces the previous long form survey) provides the backbone of detailed datanecessary for transportation planning activities required under Title 23: Highways, Part 450 ­Planning and Assistance Standards. In addition to severely hindering the abilities of state andmetropolitan planners to meet Federal statutes and related guidance as developed anddistributed by the US Federal Highway Administration (FHWA), US Federal TransitAdministration, Environmental Protection Agency (EPA), and others, the proposed changes todata available under the American Community Survey (as posted in the March 6, 2009 FederalRegister) will also hurt small rural communities, low income communities, and otherenvironmental justice populations where English is not the primary spoken language.

The American Community Survey was fully implemented in 2005 with the support of Congressand replaces the long form of the Census. Through the American Community Survey, the USCensus Bureau collects, "Detailed data for socioeconomic characteristics over the course of thedecade providing yearly, up-to-date information to federal users and our nation's communities." TheAmerican Community Survey also provides, "Timely, accurate information for every county, city, andneighborhood-the level where the most crucial decisions affecting American communities are made." II

For transportation planning applications, it is understood that the 5-year American Community Surveywill produce data similar to that previously provided in the Census long form. A report published by theUS General Accounting Office (GAO) notes that, "According to the (Census) Bureau, the 5-yearaverages, which would be available at the detailed long-form level of geographic detail, would be aboutas accurate as the long-form data." iii

Because the American Community Survey was to serve as the replacement of long-form data, thenational transportation community responded with a new set of Census Transportation PlanningProdUcts that rely on data from the 1-year, 3-year, and 5-year American Community Survey datatabulations. These data on work trip length, household income, means of travel to work, educationallevel, race and ethnicity information, have been used since the advancement of transportation planningin the post World War 2 interstate era, to quantitatively analyze and predict demand for transportationsystems and services. Analysis is typically conducted on the basis of small geographic units that arecomprised of a collection of several blocks (block group) in urban areas - that are encoded as trafficanalysis zones.

"The mission ofthe Oklahoma Department ofTransportation is to provide a safe, economical, andeffective transportation networkfor the people, commerce and communities ofOklahoma. "

AN EQUAL OPPORTUNITY EMPLOYER

Page twoApril 17, 2009Schechter

Using this information and cross-tabulating with other census variables has allowed planners toplan accurately and efficiently for future transportation needs. Based on the best analysis possible,NO Block Group (average size: 600 people) data will be released by the Census Bureau for"Means of Transportation to Work" when it is used in a crosstab. In fact, little to no Tract level(Minimum size: 1200 people) data for "Means of Transportation to Work" data will ever make it pastthe proposed new rule.

It is understandable that data collected over a 3 or 5 year period will include a smaller sample sizethan when that data was collected 1 time every ten years. The transportation data questions werepreviously asked of 16 out of 100 households. So, for example, if those 16 households are nowsurveyed over a 5 year period, the likelihood of being able to associate the data (from the 3households surveyed each year with actual individuals in dwelling units) is indeed greater.However, we are aware that statisticians and analysts at the FHWA and Census Bureau haveproposed sophisticated methods of delivering useful data to the transportation planning community- while still preserving the confidentiality of individual respondents. Suppressing the data is not thebest answer. The Department should allow more time for talented and capable analysts to betterassess the impacts of disclosure avoidance rules and to assist the Census Bureau in developingsolutions to meet the needs of the planning community.

By limiting the detailed tabulations as proposed, the American Community Survey will not, in fact,accomplish the goal noted in the March 6 Federal Register, which notes, "One Goal of the(American Community Survey) is to provide small area data similar to the data published afterCensus 2000, based on the long-form sample." If the posted changes to the American CommunitySurvey take effect, Census Transportation Planning Products will provide limited value." iv To thisend, AASHTO Standing Committee on Planning, with the Census Transportation PlanningProducts Oversight Board, has noted the following related limitations as they pertain to statewide,metropolitan, and local! community planning, where the proposed changes to the Americancommunity Survey would:

• Prohibit metropolitan areas from meeting planning requirements detailed in 23 CFR450.322, where data at the traffic analysis zone and block-group levels are required. Thiswill primarily affect analysis of journey-to-work for most tracts, block groups, and trafficanalysis zones. Additionally, detailed analysis for transit routes and bicycle and pedestrianpathways will be greatly hindered, since limited data for these analyses is already limited.

• Hinder the calibration and development of accurate travel demand models andregional transportation needs assessment. Proposed legislation for surfacetransportation reauthorization, while still in draft form, will likely mandate additionalmonitoring and reporting across states and metropOlitan regions. Limits on data availabilitywill hamper the usefulness and development of activity-based models and accessibilitymetrics which rely on these detailed data, as well as the calibration of current traveldemand models. This will also greatly limit efforts related to emergency response planningfor hurricanes and other large scale incidents.

• Limit the efforts of local, regional, and statewide efforts to minimize the impacts oftransit projects and transportation enhancement on environmental justicepopulations and to provide services for these populations, including programs relatedto job access and reverse commutes.

Page threeApril 17, 2009Schechter

• Limit the ability of the transportation community to evaluate transportation choicesand land use patterns; a critical need in the context of moving forward to look atalternatives to the single occupant motor vehicle.

In sum, the proposed rules as detailed within the March 6, 2009 Federal Register will clearly andadversely affect the ability of state, metropolitan, and local planning organizations to deliver ongoals and objectives mandated in Federal law as well as those supported under Executive Orderby FHWA, FTA, and EPA, as critical for enhancing statewide, metropolitan, and rural economies.We urge the Department of Commerce NOT to adopt the proposed scheduled and line of dataproducts from the 5 year ACS estimates. Further we strongly encourage the Department tocollaborate with the U.S. DOT, the Transportation Research Board, and academics to develop aresponsible informative solution to this difficult issue.

References: Federal Register, March 6, 2009AASHTO Standing Committee on Planning

Sin r@ly,

Gi /er~~,p.EDivision Engi eerResearch and Planning Division

CC: David Streb, Director of EngineeringEmail: Susan.Schechter.Bortner@census.gov

i See: http://www.census.gov/acs/www/Downloads/FedRegNotice E9-4803.pdfii According to the Prepared Statement ofCharles Louis Kincannon, Director, US Census Bureau, before theSubcommittee on Federal Financial Management, Government Information and International Security Committee onHomeland Security and Governmental Affairs, US Senate, 6 June 2006.http://hsgac.senate.gov/public/ files/060606Kincannon.pdf.iii The US Government Accountability Office, The American Community Survey: Accuracy and TimelinessIssues, 30 Sep 2002, http://www.gao.gov/products/GAO-02-956R.iv The CTPP products have been custom tabulated to match Traffic Analysis Zones (TAZ) - the standard level ofgeography for the modeling process. Because TAZs are inherently small areas, new disclosure rules would suppressdata at the TAZ level.

Chair Willa Johnson Oklahoma County Commissioner Vice-Chair Kathy Walker Nichols Hills Mayor Secretary/Treasurer Mark Sharpton Logan County Commissioner Executive Director John G. Johnson

April 20, 2009 Susan Schechter, Chief American Community Survey Office Room 3K276 MS 7500 Washington, D.C. 20233-7500 Dear Ms. Schechter: Thank you for the opportunity to comment on the proposed data products for the first 5-year AMERICAN Community Survey (ACS) and the “Restrictions on the Release of ACS Five year Data Products Required for Disclosure Avoidance.” These restrictions and rules govern the proposed data products for the first 5-year ACS. For transportation planning applications, it is understood that the 5-year ACS will produce data similar to that previously provided in the Census long form. A report published by the US General Accounting Office (GAO) notes that, “According to the (Census) Bureau, the 5-year averages, which would be available at the detailed long-form level of geographic detail, would be about as accurate as the long-form data.”1 Because the American Community Survey was to serve as the replacement of long-form data, the national transportation community responded with a new set of Census Transportation Planning Products that rely on data from the 1-year, 3-year, and 5-year American Community Survey data tabulations. By limiting the detailed tabulations as proposed, however, the American Community Survey will not, in fact, accomplish the goal in the March 6 Federal Register, which notes, “One Goal of the (American Community Survey) is to provide small area data similar to the data published after Census 2000, based on the long-form sample.” If the posted changes to the 5-year products of the American Community Survey take effect, Census data will be of limited value to the transportation community.2 To this end, AASHTO Standing Committee on Planning, with the

-.1acog

association ofcentral oklahoma governments

21 E Main Street, Suite 100 Oklahoma City, OK 73104·2405 4052342264 FAX 234 2200 TTY 234 2217 www.acogok.org

Susan Schechter Page 2 April 20, 2009 Census Transportation Planning Products Oversight Board, has noted the following related limitations as they pertain to statewide, metropolitan, and local/ community planning, where the proposed changes to the American Community Survey would: • Prohibit metropolitan areas from meeting planning requirements detailed in 23 CFR 450.322, where data at the block-group level are required. This will primarily affect analysis of journey-to-work for most tracts and block groups. Additionally, detailed analysis for transit routes, enhancements, and New Starts will be greatly hindered, since data for these analyses is already limited. • Hinder the calibration and development of accurate travel demand models and regional performance metrics. Proposed legislation for surface transportation reauthorization, while still in draft form, will likely mandate additional performance monitoring and reporting across states and metropolitan regions. Limits on data availability will curtail the usefulness and development of activity-based models and accessibility metrics which rely on these detailed data, as well as the calibration of current travel demand models. This will also greatly limit efforts related to emergency response planning for hurricanes and other disasters. • Limit the efforts of local, regional, and statewide efforts to minimize the impacts of transportation enhancements on environmental justice populations and to provide services for these populations, including programs related to job access and reverse commute, mobility needs of transit-dependent populations and temporary assistance for needy families, improvements for American’s with disabilities, and others. • Limit the ability of the transportation community to evaluate transportation choices and land use patterns; a critical need in the context of national climate change strategies. Those involved in the climate change debate have argued for more, not less, data availability to fully understand these relationships. In sum, the proposed rules as detailed within the March 6, 2009 Federal Register will clearly and adversely affect the ability of state, metropolitan, and local planning organizations to deliver on goals and objectives mandated in Federal law as well as those supported under Executive Order by FHWA, FTA, and EPA, as critical for enhancing statewide, metropolitan, and rural quality of life. The transportation community needs more information from the US Census Bureau, as well as more time, to better assess the impacts of disclosure avoidance rules and to provide suggestions for solutions to meet the needs of the planning community. Understandably, some data from the American Community Survey may not be suitable for dissemination and use by the general public; however, providing these data, including caveats regarding reliability, to state and local governments to maintain and enhance decision-making is essential for the transportation planning activities required by Federal law

Susan Schechter Page 3 April 20, 2009 and necessary for ensuring responsible transportation planning for all Americans in metropolitan and rural areas alike. The Association of Central Oklahoma Governments, the Metropolitan Planning Organization for the Oklahoma City area, is very concerned about the implications that the level of data disclosure will have on the effectiveness of the 2010 Census Transportation Planning Package (CTPP). If the data disclosure is limited by the March 6, 2009 Federal Register proposals, then the investment by states and MPOs in the 2010 CTPP was a poor decision. Money spent on that program would have been more wisely spent on local surveys to use for modeling purposes. The increased necessity for all transportation mode information will be thwarted by this proposed rule. In conclusion, MPOs are being asked to model all modes of transportation at small levels of geography in order to be more precise. In some cases, the 5-year ACS products will only be available at the place level and higher. This is a step backwards from the 2000 Census and could result in less accurate and more generalized transportation planning. Sincerely, John Sharp, Program Coordinator Transportation Planning & Data Services

NOTES                                                             1 The US Government Accountability Office, The American Community Survey: Accuracy and Timeliness Issues, 30 Sep 2002, http://www.gao.gov/products/GAO-02-956R.  2 The CTPP products have been custom tabulated to match Traffic Analysis Zones (TAZ) – the standard level of geography for the modeling process. TAZs are inherently small geographic areas and the new disclosure rules would suppress valuable data required at the TAZ level. 

"Ahmad Jaber" <ajaber@utah.gov>

04/18/2009 09:46 AM

To

<Susan.Schechter.Bortner@census.gov> cc

"Penelope Weinberger" <pweinberger@aashto.org>, "Carlos Braceras" <CBRACERAS@utah.gov>, "Charles Chappell" <CHARLESCHAPPELL@utah.gov>, "Chris Newman" <CWNEWMAN@utah.gov>, "Walter Steinvorth" <MSTEINVORTH@utah.gov>, <mary.tischer@virginiadot.org>

Subject Re: Response to FR Notice regarding ACS 5-year Data Products

Dear Susan, The following is the UDOT response to the Federal Registrar notice of March 6th regarding Census Bureau's proposal for ACS 5-year data products: The Utah Department of Transportation (UDOT) strongly opposes the action proposed by the US Census Bureau as noted in the March 6, 2009 Federal Register to revise the American Community Survey 5-year data planning products. The Department has initiated several planning initiatives that rely on these products. In addition to the reasons listed by AASHTO‘s letter of opposition, UDOT offers the following: UDOT and all of the Metropolitan Planning Organizations initiated a more collaborative approach to long range transportation planning several years ago. The product of this initiative was an award winning Unified Long Range Plan. This activity was recognized and received awards from both AASHTO and AMPO in planning. Much of the analysis was dependent on data from Census Transportation Planning Products and the American Community Survey. Utah is geographically a very large state with the majority of the population living and working in the six urbanized counties Utah, Salt

Lake, Davis, and Weber, Cache, and Washington. The remaining twenty-three counties are rural with small cities and small populations. Utah Department of Transportation has recognized the need for good planning in these counties and has initiated an Emerging Area Planning Process to help theses areas develop their plans. The American Community Survey would be a critical data source for these planning activities. UDOT is also developing a Statewide Travel Demand Model to aid in planning and project prioritization. The American Community Survey will also be critical to this effort. The only other way to obtain data and information provided through Transportation Planning Products would be through expensive statewide surveys. The proposed changes will definitely reduce our ability to meet the goals and objectives mandated by Federal law. It will also adversely hurt the planning initiatives we have started. We have that you will reconsider the proposed action.

JENNIFER M. GRANHOLMGOVERNOR

STATE OF MICHIGAN

DEPARTMENT OF TRANSPORTATIONLANSING

April 17,2009

KIRK T. STEUDLEDIRECTOR

Ms. Susan Schechter, ChiefAmerican Community Survey OfficeRoom3K276Mail Stop 7500Washington, D.C. 20233-7500

Dear Ms. Schechter:

The Michigan Department of Transportation (MDOT) firmly opposes the Census Bureau's proposedaction regarding rules and restrictions relative to the five-year American Community Survey (ACS)data products as presented in the March 6, 2009 Federal Register Notice. The proposed revisions inACS five-year data products would significantly reduce the quality and quantity of census dataavailable to support transportation planning analysis in Michigan. The following discussion outlinesMDOT's position.

Rule 1 of the Notice states that "ACS estimates of Unmarried Partners and characteristics of thepopulation living in Group Quarters cannot be released at the block group level."

This means that that no block group data will be available for Group Quarters in five-year ACS dataproducts. This is particularly troubling considering that Michigan has several large military areasand college towns that comprise significant shares of the population in their respective zones andhave a large influence on the transportation network. Consequently, for some of Michigan'smetropolitan planning organizations (MPOs) where such facilities exist, the lack of small area GroupQuarters data will make federally-mandated travel demand modeling analyses more difficult.Moreover, the MPOs will have to wait until Census 2010 block-level Group Quarters data isreleased, likely not until 2012.

Rule 7 of the Notice states that "For the residence and workplace tables where means oftransportation (mode) is crossed with one or more other variables, there must be at least threeunweighted workers in sample for each transportation mode in a given place for the table to bereleased. Otherwise the data must be collapsed or suppressed and complementary suppression mustbe applied. There is no threshold on univariate tables."

The Federal Highway Administration (FHWA) has observed (and MDOT concurs) that although thismay seem very straight forward, we know from the "statistical collapsing" rules that were applied tothe three-year data that only one collapsing attempt is made of the data and if the table does not pass,it is discarded (suppressed). What we do not know about the current rule is what will the collapsinghierarchy be, and will the Census continue collapsing modes into each other until the threshold ismet? Both the Federal Register notice and the rules are silent on this issue. In some recent workdone for FHWA by the Census Bureau, it was found that, at a tract level, a great deal of data will besuppressed under Rule 7. At the block group, the suppression will likely be worse. FHWA has also

MURRAY D. VAN WAGONER BUILDING· P.O. BOX 30050· LANSING, MICHIGAN 48909www.michigan.goY· (517) 373-2090

LH-LAN-O (01/03)

Ms. Susan SchechterPage 2April 17, 2009

determined from this rule that all block group and most tract data for "Means of Transportation toWork" crossed with any variable, even gender, will likely never be available! Essentially, the overalleffect of applying Rule 7 severely restricts MDOT's ability to draw meaningful conclusions aboutthe state's travel behavior.

Implications for MDOT

• Considering the resulting data suppression of applying these rules, the Census Bureau'sproposal would severely limit the usability of small area (tract, zone, block group) censusdata for multimodal planning.

• The Census Bureau's proposed action is not aligned with established federal policy fortransportation planning. The prospect of less detailed census data available at the trafficanalysis zone, block group, and tract levels suggests that there was little consideration givento how this would adversely affect the ability of metropolitan areas to meet the federally­mandated planning requirements of Title 23 - Code of Federal Regulations 450.322(a).

• The Census Bureau's proposed action is not aligned with prevailing United StatesDepartment of Transportation and the Transportation Research Board policy calling for statesand MPOs to pursue more advanced transportation modeling tools such as activity-and tour­based models. These advanced modeling approaches require more detailed data availablefrom the Census, as well as other sources. However, the proposed action would result in lessdetailed data being available for such modeling efforts than in 2000.

• State departments of transportation commonly use a travel demand model as a tool withwhich to meet federally-mandated transportation planning processes. Such models aid inprojecting future traffic, identifying systems deficiencies, testing alternative transportationplans, and assessing air quality and safety issues on the transportation system. To be mosteffective, these models require detailed geographic data at both the residence and destinationsides of travel, as well as flow information used for purposes of constructing models.Without small area data, model calibration and validation becomes a very difficult exercise.

Other Observations

• Disclosure avoidance rules should be applied consistently to all variables when assessingdisclosure risk and establishing restrictions on data availability. The variable, "Means ofTransportation to Work," should not be singled out and subjected to more stringent rules thanother variables which have many more cross-tabulations.

• While it is understandable and commendable that the Census Bureau is adhering to Title 13requirements, a balance needs to be achieved between protecting privacy and providinguseful data to the transportation planning community. To minimize the risk of individualdisclosure, the Census Bureau already applies methods such as data swapping, imputation,and top-coding. We recommend that other statistical approaches be explored that couldfurther protect individual confidentiality while improving data accessibility.

Ms. Susan SchechterPage 3April 17,2009

• The addition of a county-to-county worker flow tabulation would be helpful. The Office ofManagement and Budget issued a Federal Register notice regarding the delineation ofmetropolitan areas, including the incorporation of county-to-county worker flow counts usingfive years ofaccumulated ACS records.

• The Census Bureau states that because "many of the estimates at the block group level willnot be reliable," block group data would not be released with other data products. Webelieve the Census Bureau should release the block group data along with the other dataproducts, and include a statement about the reliability. The block group data should be madeavailable in both American Fact Finder and in the ACS Data Download area, given theimportance of this data for travel forecasting.

• In the March 6, 2009 Federal Register Notice (pg 9786), the Census Bureau states: "Therelease of the five-year estimates will achieve a goal of the ACS to provide small area datasimilar to the data published after Census 2000, based on the long-form sample." Theexpectation of the ACS has always been that after a five-year accumulation of data, it willproduce similar data products as the traditional long-form. The combination of smallersamples (given the design of the ACS) and the unweighted records threshold requirementsfor tabulation, results in an ACS product that can primarily be used for residence tabulationsonly, with limited workplace tabulations and flow data limited to total worker counts. Thisfalls far short of the expectations for the ACS products. In the long run, the Census Bureaushould consider alternatives to the ACS that would provide the much needed small area flowdata, which is essential for meeting transportation planning requirements.

Thank you for the opportunity to review and comment on the Census Bureau's proposedmodifications to its five-year ACS data products, as listed in the March 6, 2009 Federal Registernotice. Essentially, the proposed rules within the notice are unclear as to how these rules will affectvarious tables and program areas. The transportation planning community needs more informationfrom the Census Bureau to analyze the effect of disclosure avoidance rules and develop strategies tohandle the projected data void.

Sincerely,

~~Susan P. Mortel, DirectorBureau of Transportation Planning

EXECUTIVE COMMITTEE

PRESIDENT Joe A. Garcia Ohkay Owingeh (Pueblo of San Juan)

FIRST VICE-PRESIDENT Jefferson Keel Chickasaw Nation

RECORDING SECRETARY W. Ron Allen Jamestown S’Klallam Tribe

TREASURER gaiashkibos Lac Courte Oreilles

REGIONAL V ICE PRES IDENTS

ALASKA Mike Williams Akiak Native Community

EASTERN OKLAHOMA Joe Grayson, Jr. Cherokee Nation

GREAT PLAINS Ron His Horse is Thunder Standing Rock Sioux Tribe

MIDWEST Robert Chicks Stockbridge-Munsee

NORTHEAST Randy Noka Narragansett

NORTHWEST Brian Cladoosby Swinomish Tribe

PACIFIC Juana Majel Pauma-Yuima

ROCKY MOUNTAIN Scott Russell Crow Tribe

SOUTHEAST Archie Lynch Haliwa-Saponi Tribe

SOUTHERN PLAINS

Darrell Flying Man Cheyenne-Arapaho Tribe

SOUTHWEST Derek Valdo Pueblo of Acoma

WESTERN Alvin Moyle Fallon Paiute Shoshone Tribe

EXECUTIVE DIRECTOR Jacqueline Johnson Tlingit

NCAI HEADQUARTERS 1301 Connecticut Avenue, NW Suite 200 Washington, DC 20036 202.466.7767 202.466.7797 fax

N A T I O N A L C O N G R E S S O F A M E R I C A N I N D I A N S

NCAI Comments on Proposed Data

Products for 5-year ACS Estimates

The following comments are submitted in response to the Census Bureau's request for

comments in the March 6, 2009 Federal Register Notice concerning the data products

to be issued with information from the 5-year estimates produced by the American

Community Survey (ACS).

Types of Data Products

With the exceptions discussed below, all the proposed data products for American

Indian Areas/Alaska Native Areas (AIA/ANAs) contain figures on the total population

of all races. This data presents a seriously misleading picture of the characteristics of

the population in such areas.

Casual data users, including tribal leaders and staff, are likely to make an implicit

assumption that the data for federal reservation areas represent the conditions for the

Native people in such areas. However, the AI/AN Alone population constitutes less

than half the total population on nearly one-third of the reservations in the country

with the largest AI/AN populations.

Socio-economic conditions on reservations with substantial non-Native populations

differ markedly between Native and non-Native people. The Wind River reservation

illustrates the problem. According to the 3-year ACS data, the AI/AN Alone

population constitutes only 25.7% of the total population on that reservation. There

are marked differences between the characteristics of the AI/AN and the total

population. The table below shows the extent of these differences with respect to

several key social and economic indicators:

Pct with

less than Unemployment Poverty

Population HS/GED Rate Rate

AI/AN Alone 19.0% 14.0% 27.7%

Total Population 12.7% 4.4% 13.0%

The contrast in characteristics would be even greater if the table showed the data for

the AI/AN Alone and the non-AI/AN Alone populations.

The potential for confusion among casual users in interpreting the data for

AIA/ANAs, particularly federal reservations, is present in the data profiles -- the most

readily accessible products, available not only on the Bureau's Web site but also those

of many state data centers. The same potential for confusion is present in the narrative

profiles, the subject tables and the geographic comparison tables.

Page 2 of 3

To reduce the possibility for such confusion, it is strongly recommended that:

• The Census Bureau add a note to the bottom of each of these products for

every AIA/ANA to the effect that the data displayed in this product

represents data for the total population of all races, not the AI/AN

population.

• The Bureau, in cooperation with the AI/AN Census Information Centers

and other AI/AN partner organizations, conduct an intensive educational

campaign for AI/AN data users to insure that users are aware of the

disparities that exist among conditions for the AI/AN population and the

non-AI/AN population in AIA/ANAs.

A number of tables in the detailed table product, as well as the selected population profiles, do

enable the user to obtain data for the AI/AN Alone or AN/AN Alone or in Combination

populations. However, in order to choose the appropriate tables in the detailed table product, the

user must have a working familiarity of the hundreds and hundreds of tables from which to make

a selection.

As to the selected population profiles, the 3-year estimates product now on the Web has no

profiles for the AI/AN Alone population in any reservation area and only one such profile for an

Oklahoma Tribal Statistical Area and one for a State Designated Tribal Statistical Area. Whether

this absence of selected population profiles for the AI/AN population in AIA/ANAs represents

the effect of disclosure avoidance rules is unclear.

Readily accessible profiles with appropriate characteristics information on the AI/AN population

in AIA/ANAs should be made available through the use of the ACS AI/AN Summary File,

promised in the March 6th Federal Register Notice. However, as the specifications for that

Summary File will be contained in a later Notice, it is impossible to comment on it at this time.

In addition, the other ACS data products, such as the data profiles, are likely to be available much

sooner than the AI/AN Summary File.

Restrictions Required for Disclosure Avoidance or Statistical Reliability

The implications of the restrictions on the release of ACS 5-year data products on the availability

of data for the AI/AN population in AIA/ANAs are unclear.

The Bureau's proposal indicates that there must be at least 50 unweighted sample cases over the

5-year period for any selected population profile to be released. This would appear to have the

effect of suppressing such profiles for at least some small reservations, perhaps many Alaska

Native Village Statistical Areas, and at least some tribal subdivisions.

The Bureau should provide an estimate of how many such areas might be affected.

It would appear that there are no other significant restrictions. However, the small AI/AN

populations in a number of AIA/ANAs would seem to make some form of disclosure avoidance

necessary. What little information is available on the three small reservations included in the

Page 3 of 3

Multi-Year Estimates study appears to show that there are potential disclosure and statistical

reliability issues with respect to similar areas.

What procedures does the Bureau intend to implement to protect the confidentiality of

individual responses in such areas?

Proposed Geographic Summary Levels for Selected 5-year Products

The table of proposed geographic summary levels for selected ACS 5-year data products

contained in the Bureau's proposal raises at least one important question for AI/AN data users.

What products will be available for county portions of federal reservation areas?

The table indicates that no data products will be available for summary level 270, relating to the

portion of an AIA/ANA within a given state and county. This would represent a significant

problem for users wishing to distinguish the size and characteristics of the population for the

areas of a county within and outside of reservation boundaries.

The Bureau should make one or more products available with data for the AI/AN and total

populations of county portions of federal reservation areas.

"DeLania Hardy" <dhardy@ampo.org>

04/20/2009 05:12 PM

To

<Susan.Schechter.Bortner@census.gov> cc

Subject

AMPO ACS Response letter Apr 2009.doc

April 20, 2009

Susan Schechter, Chief, American Community Survey Office, Room 3K276, Mail Stop 7500, Washington, DC 20233–7500 Dear Ms. Schechter: On behalf of the members of the Association of Metropolitan Planning Organizations (AMPO), I am writing in response to the March 6, 2009 Federal Register notice to revise the American Community Survey 5-year data planning products. AMPO strongly opposes the action proposed by the Census Bureau as noted in the March 6, 2009 Federal Register to revise the American Community Survey 5-year data planning products. The American Community Survey is a critical data source MPOs and their partners to conduct transportation planning that guides transportation investment decisions. The proposed changes will hinder the abilities of MPOs to meet federal planning requirements developed by USDOT and USEPA. Implementing the changes proposed will not accomplish the goal put forth in the March 6 Federal Register, which notes, “One Goal of the (American Community Survey) is to provide small area data similar to the data published after Census 2000, based on the long-form sample.” If the posted changes to the 5-year products of

the American Community Survey take effect, Census data will be of limited value to the transportation community. AMPO as well as some of our members participate on the Census Transportation Planning Products Oversight Board (CTTP). We have also participated with AMPO in discussion of the March 6th Federal Register notice, and together we note that the proposed ACS would:

• Prohibit metropolitan areas from meeting planning requirements detailed in 23 CFR 450.322, where data at the block-group level are required. This will primarily affect analysis of journey-to-work for most tracts and block groups. Additionally, detailed analysis for transit routes, enhancements, and New Starts will be greatly hindered, since data for these analyses is already limited. • Hinder the calibration and development of accurate travel demand models and regional performance metrics. Proposed legislation for surface transportation reauthorization, while still in draft form, will likely mandate additional performance monitoring and reporting across states and metropolitan regions. Limits on data availability will curtail the usefulness and development of activity-based models and accessibility metrics which rely on these detailed data, as well as the calibration of current travel demand models. This will also greatly limit efforts related to emergency response planning for hurricanes and other disasters. • Limit the efforts of local, regional, and statewide efforts to minimize the impacts of transportation enhancements on environmental justice populations and to provide services for these populations, including programs related to job access and reverse commute, mobility needs of transit-dependent populations and temporary assistance for needy families, improvements for American’s with disabilities, and others. • Limit the ability of the transportation community to evaluate transportation choices and land use patterns; a critical need in the context of national climate change strategies. Those involved in the climate change debate have argued for more, not less, data availability to fully understand these relationships.

We believe the transportation community needs more information and more time from the US Census Bureau to better assess the impacts of disclosure avoidance rules and to provide suggestions for solutions to meet the needs of the planning community. We do understand that some data from the ACS may not be suitable for dissemination and use by the general public; however, providing these data, including caveats regarding reliability, to state and local governments to maintain and enhance decision-making is essential for the transportation planning activities required by Federal law and expected by the public. Thank you for the opportunity to comment. Please contact DeLania Hardy, AMPO Executive Director, with any questions. She can be reached at (202) 296-7051. Sincerely, DeLania Hardy

"Flintoft, Anna E." <Anna.Flintoft@ci.minneapolis.mn.us>

04/21/2009 02:25 PM

To

<Susan.Schechter.Bortner@census.gov> cc

"Filipi, Mark" <Mark.Filipi@metc.state.mn.us>, "Pflaum, Donald C." <Donald.Pflaum@ci.minneapolis.mn.us>, "Schroeder, Greg A." <Greg.Schroeder@ci.minneapolis.mn.us>

Subject ACS Proposed 5 year products

Susan Schechter Chief, American Community Survey Office U.S. Census Bureau Dear Ms. Schechter: I realize the April 20 deadline has passed for comments on the proposed ACS 5 year products, but I just came across the information yesterday, and I hope that my comments may be considered. I have been using the ACS products for tracking trends in transportation mode share and am looking forward to more current information on transportation mode share for our downtown central business district. Unfortunately, it appears to me from the list of proposed 5 year products that the smallest geography for means of transportation to work by workplace geography will be “place,” which would not allow us to report on mode to work for downtown Minneapolis. This does not appear to be the case for means of transportation to work by place of residence, which has much smaller geographies than “place.” Frankly, reporting on mode share by place of residence small geographies is significantly less useful to us than by place of work small geographies. There are more workers in downtown Minneapolis than in many “place” geographies, so I would assume that confidentiality should not be a problem. Please consider providing workplace geographies small enough to be able to report on sub-areas of large cities, especially central business districts. Thank you for your consideration. Sincerely, Anna Flintoft * * * * * * * * * * * * * * * * * * * * * * * * Anna Flintoft, PTP Transportation Planner Department of Public Works - Transportation Planning and Engineering City of Minneapolis Room 301, City of Lakes Building 309 2nd Avenue South Minneapolis, MN 55401

(612) 673-3885 (office) (612) 269-9410 (cell) anna.flintoft@ci.minneapolis.mn.us * * * * * * * * * * * * * * * * * * * * * * * *

Ken Hodges Nielsen Claritas 53 Brown Road Ithaca, NY 14850 March 26, 2009 Susan Schechter Chief, American Community Survey Office Room 3K276, Mail Stop 7500 Washington, DC 20233-7500 I appreciate the opportunity to comment on the proposals for 5-year data from the American Community Survey. My comments are from the perspective of a demographer working for a private supplier of information products to a wide range of users in both the private and public sectors. They are not necessarily the views of the company. Private sector applications tend to focus on very small areas, and ambitious levels of detail, so many business users are looking to the ACS as the new source for such data. There is great interest in the availability of ACS data for all block groups, and emphasis on the reduction in error achieved when block groups are aggregated to custom areas. Any suppression or reduction of detail is a problem for such applications. With these basic interests in mind, the proposals in the March 6 Federal Register notice suggest 5-year ACS products that will be valuable to many business users. My thoughts on specific issues follow. 1. Releasing 5-year data for block groups. This release of block group data is a very high priority for many business users. 2. Not providing some products for block groups. For our purposes, the Detailed Tables are the key. A lack of Narrative Profiles and other re-packaging products for block groups is not a big deal. 3. Applying reliability checks, collapsing, and suppression to 5-year ACS data. This would be a major problem for business users, as it would impair the ability to aggregate ACS data to custom areas. The proposal to exempt the 5-year data from collapsing and suppression will strengthen private sector support for the ACS. In fact, some have found the collapsing and suppression of 1-year and 3-year data to be a problem, and would argue for the full release of those data as well. For example, a business might want the more current 1-year estimates of income by age of householder for an aggregation of six counties. If the table is suppressed for one county (due to reliability), the business would have to use less current 3-year, or maybe even 5-year data for the area.

4. Limitations for purposes of disclosure avoidance. With a few exceptions, the proposal is to provide 5-year ACS data for Detailed Tables for which 3-year data are provided – with no suppression for disclosure avoidance. This is good news for business users, and important for the objective of long form replacement. An exception is that 5-year data would not be provided for tables with more than 100 cells. This is unfortunate, but still leaves room for considerable detail. In fact, some tables (such as income by age of householder) could show additional detail, and still be under the 100 cell limit (the reduction from 112 cells in SF3 to only 64 in ACS is severe). And I assume that the Sex by Age Detailed Tables (28 cells each, and presented separately for race categories) are treated as separate tables for this purpose, and not considered as one large Sex by Age by Race table. Such a limitation would need to be explained to users. The other limitations relate primarily to journey to work and workplace tabulations. These limitations might present significant problems for transportation planners and others who use these tabulations. Of particular concern is the requirement for at least three unweighted workers in each transportation mode for tables where transportation is crossed with one or more other variables. Presumably, even a Detailed Table as basic as Sex of Workers by Means of Transportation to Work would be subject to this limitation. If this is the case, we would at least need journey to work tables for total workers (not crossed by other variables). All the journey to work tables I see now are crossed by at least one other variable. It would also be helpful to know why the journey to work and workplace tables are considered to need greater disclosure protection. 5. Annual release of 5-year ACS data. Annual updates have been a major ACS selling point, so the proposal for annual releases of 5-year ACS data looks like exactly what users need and expect. Thank you again for the opportunity to comment on the proposals for 5-year ACS data. We appreciate that the ACS is still a work in progress, and look forward to working with the Census Bureau to help maximize the value of the new survey to a wide range of users. Sincerely, Ken Hodges

Iowa Department of Transportation800 Lincoln Way, Ames, fA 50010 515-239-1664

Fax: 515-233-7857

March 31, 2009

Susan Schechter, ChiefAmerican Community Survey OfficeRoom 3K276, Mail Stop 7500Washington, DC 20233-7500

Re: Federal Registerl Vol. 74, No. 431 Friday, March 6, 20091 Notices

Dear Ms. Schechter:

This letter is in reference to Federal Register Volume 74, No. 431 Friday, March 6,2009, Docket Number 090130099-9106-07, American Community Survey 5-Year DataProducts.

The Iowa Department of Transportation has concerns regarding the geographic leveland, overall quaJityoftransportationc:iata thatwill.be available through the AmericanCommunity Survey... Since th~.t970decennial census, .. the 10watr(3nspqrtationplannipg cOrrlmunityhCl~reliec:ion the Cel1sus 1ransportatiol1 Planning Pacl(age(SJPP) ahd,. its'data .. produqts,tosupport federally,.mandated transportationp!anningreql.lirements asspecifiecl.inSAfETEA,.LU.. Examples of theserequirements(3re traveldernandmodeling, long-range transportation plan development, ·airQlJ(3lity.andenvironmental analyses, rail and bus transit studies, policy andinvestmel1t scenarios.

Until the 2000 decennial Census, ctpp data products were developed fromtransportation related questions include.d on the Census "long form." A great deal ofeffort and cost was expended by state Departments of Transportation and MetropolitanPlanning Organizations to design the CTPP products to meet their analytical needs.The CTPP data products have become one of the most utilized data sources fortransportation planning in Iowa and throughout the nation.

In 2005, the US Census Bureau decided to eliminate. the "long form" and replace it withthe American Community Survey (ACS). The national transportation communityquicklyresponded to the Census Bureau's decision and began to formulate a processto create a new set of CTPP data products that would be based on the ACS. In 2006,AASHTO approved a new Census Transport(3tignplanning Products program thatfocUSrcl on providing the same level of data that was previously availaqle from theC~n~ys long form,Thenew CTPP data products ,Will use qata from the ACS toproduce on,e-year, three.,yearandJive-year data tabu]atigps to support ayarietyofstate'(3nd local transportationpl(3nningefforts, The developl1Jentofthes~newdatasetshas the potential to save. a significant amounfoftime; effort andJinancial reSOlJrces.vvithout.the new ACS-ba.sed.CTPP data, each state and/orMPqwould othervyisebe

Susan SchechterMarch 31, 2009Page 2

required to collect and fund travel data on their own. In many cases this would not befeasible, thus significantly reducing an agencies ability to meet their transportationplanning responsibilities.

Our concern rests mainly with the level of geography the ACS data will be reported andthe issue of the new disclosure rules set by the Census Bureau Disclosure ReviewBoard. The analytical process for transportation planning has been based on a varietyof geographic levels. Most notably is the travel demand modeling process whichrequires census data at smaller than typical levels of geography. The CTPP productshave been custom tabulated to match Traffic Analysis Zones (TAZs) Which is thestandard level of geography for the modeling process. However, because TAls areinherently smaller areas in size, the new disclosure rules would suppress the data atthe TAl level rendering it useless. It is understood the intent is to protect anindividual's confidentiality; however, it is highly unlikely a breach would actually berealized. Having access to CTPP data at the TAl level is critical for a number ofanalytical purposes.

Additionally, the new disclosure requirements specify that tables with a cross-tabulationusing the variable "means of transportation to work," need to meet disclosurerequirements for each category of travel mode; or else the table would be suppressed.It has become clear through testing with samples of the three-year product thatapplying the new disclosure requirements, specifically for the CTPP data products,there is the possibility that many tables could be suppressed, meaning the data wouldbasically be useless for many of our transportation planning purposes.

Given the data obtained from the CTPP data products may be very limited in theiroverall use for transportation planning, the burden then falls to the state and the localsto obtain data that can be used to meet their federally-mandated requirements. Thissituation would then require additional time, effort and money to develop data sufficientto meet the analytical needs.

The CTPP data products have been a staple for transportation planning for nearly fourdecades and the transportation community requests the integrity of the new ACS andCTPP data be maintained.

Sincerely,

Stuart Anderson, DirectorPlanning, Programming and Modal Division

SApir

From: jean public [jeanpublic@yahoo.com] Sent: 03/06/2009 05:05 AM PST To: Susan Schechter Bortner; americanvoices@mail.house.gov Cc: nytimes nytimes <jersey@nytimes.com>; info@taxpayer.net; media@cagw.org Subject: *****SPAM***** (9.629/4) Fw: CUT ALL OF THIS EXTRANEOUS STUFF OUT AND JUST DO A TEN YEAR CENSUS public comment on federal register you cant even have the ten year census figured out, which is your main job. why are you doing endless extraneous jobs spendign tax dollars for nothing that truly helps america. isnt it time to focus and to cut out unnecessary projects like this one appears to be. jean public 15 elm st florham park nj07932

Allen D. Biehler, President Secretary, Pennsylvania Department of Transportation

John Horsley, Executive Director 444 North Capitol Street NW, Suite 249, Washington, DC 20001

(202) 624-5800 Fax: (202) 624-5806 • www.transportation.org

April 14, 2009 Susan Schechter, Chief, American Community Survey Office, Room 3K276, Mail Stop 7500, Washington, DC 20233–7500 Dear Ms. Schechter: The American Association of State Highway and Transportation Officials (AASHTO), with input from the Standing Committee on Planning and the Census Transportation Planning Products Oversight Board, strongly opposes the action proposed by the US Census Bureau as noted in the March 6, 2009 Federal Register to revise the American Community Survey 5-year data planning products. The American Community Survey is a critical data source for transportation planning and related regional transportation investment. The Survey provides the backbone of detailed data necessary for transportation planning activities required under Title 23: Highways, Part 450 – Planning and Assistance Standards. In addition to severely hindering the abilities of state and metropolitan planners to meet Federal statutes and related guidance as developed and distributed by the US Federal Highway Administration (FHWA), US Federal Transit Administration, Environmental Protection Agency (EPA), and others, the proposed changes to data available under the American Community Survey (as posted in the March 6, 2009 Federal Register) will in fact hurt the very communities they are designed to protect: small rural communities, low income communities, and other environmental justice populations where English is not the primary spoken language. The American Community Survey was fully implemented in 2005 with the support of Congress and replaces the long form of the Census. Through the American Community Survey, the US Census Bureau collects, “Detailed data for socioeconomic characteristics over the course of the decade providing yearly, up-to-date information to federal users and our nation’s communities.” The American Community Survey also provides, “Timely, accurate information for every county, city, and neighborhood—the level where the most crucial decisions affecting American communities are made.”1 For transportation planning applications, it is understood that the 5-year American Community Survey will produce data similar to that previously provided in the Census long form. A report published by the

1 According to the Prepared Statement of Charles Louis Kincannon, Director, US Census Bureau, before the Subcommittee on Federal Financial Management, Government Information and International Security Committee on Homeland Security and Governmental Affairs, US Senate, 6 June 2006. http://hsgac.senate.gov/public/_files/060606Kincannon.pdf.

Allen D. Biehler, President Secretary, Pennsylvania Department of Transportation

John Horsley, Executive Director 444 North Capitol Street NW, Suite 249, Washington, DC 20001

(202) 624-5800 Fax: (202) 624-5806 • www.transportation.org

US General Accounting Office (GAO) notes that, “According to the (Census) Bureau, the 5-year averages, which would be available at the detailed long-form level of geographic detail, would be about as accurate as the long-form data.”2 Because the American Community Survey was to serve as the replacement of long-form data, the national transportation community responded with a new set of Census Transportation Planning Products that rely on data from the 1-year, 3-year, and 5-year American Community Survey data tabulations. By limiting the detailed tabulations as proposed, however, the American Community Survey will not, in fact, accomplish the goal in the March 6 Federal Register, which notes, “One Goal of the (American Community Survey) is to provide small area data similar to the data published after Census 2000, based on the long-form sample.” If the posted changes to the 5-year products of the American Community Survey take effect, Census data will be of limited value to the transportation community. To this end, AASHTO Standing Committee on Planning, with the Census Transportation Planning Products Oversight Board, has noted the following related limitations as they pertain to statewide, metropolitan, and local/ community planning, where the proposed changes to the American Community Survey would:

• Prohibit metropolitan areas from meeting planning requirements detailed in 23 CFR 450.322, where data at the block-group level are required. This will primarily affect analysis of journey-to-work for most tracts and block groups. Additionally, detailed analysis for transit routes, enhancements, and New Starts will be greatly hindered, since data for these analyses is already limited.

• Hinder the calibration and development of accurate travel demand models and regional performance metrics. Proposed legislation for surface transportation reauthorization, while still in draft form, will likely mandate additional performance monitoring and reporting across states and metropolitan regions. Limits on data availability will curtail the usefulness and development of activity-based models and accessibility metrics which rely on these detailed data, as well as the calibration of current travel demand models. This will also greatly limit efforts related to emergency response planning for hurricanes and other disasters.

• Limit the efforts of local, regional, and statewide efforts to minimize the impacts of transportation enhancements on environmental justice populations and to provide services for these populations, including programs related to job access and reverse commute, mobility needs of transit-dependent populations and temporary assistance for needy families, improvements for American’s with disabilities, and others.

• Limit the ability of the transportation community to evaluate transportation choices and land use patterns; a critical need in the context of national climate change strategies. Those involved in the climate change debate have argued for more, not less, data availability to fully understand these relationships.

In sum, the proposed rules as detailed within the March 6, 2009 Federal Register will clearly and adversely affect the ability of state, metropolitan, and local planning organizations to deliver on goals and objectives mandated in Federal law as well as those supported under Executive Order by FHWA, FTA,

2 The US Government Accountability Office, The American Community Survey: Accuracy and Timeliness Issues, 30 Sep 2002, http://www.gao.gov/products/GAO-02-956R.

Allen D. Biehler, President Secretary, Pennsylvania Department of Transportation

John Horsley, Executive Director 444 North Capitol Street NW, Suite 249, Washington, DC 20001

(202) 624-5800 Fax: (202) 624-5806 • www.transportation.org and EPA, as critical for enhancing statewide, metropolitan, and rural quality of life. The transportation community needs more information from the US Census Bureau, as well as more time, to better assess the impacts of disclosure avoidance rules and to provide suggestions for solutions to meet the needs of the planning community. Understandably, some data from the American Community Survey may not be suitable for dissemination and use by the general public; however, providing these data, including caveats regarding reliability, to state and local governments to maintain and enhance decision-making is essential for the transportation planning activities required by Federal law and necessary for ensuring responsible transportation planning for all Americans in metropolitan and rural areas alike. Sincerely, John Horsley Executive Director

1775 Massachusetts Avenue, NW Washington, DC 20036 telephone 202.797.6139 fax 202.797.2965 web brookings.edu

Metropolitan Policy Program

April 20, 2009 Ms. Susan Schechter Chief, American Community Survey Office Room 3K276, Mail Stop 7500 Washington, DC 20233-7500

Via email: Susan.Schechter.Bortner@census.gov

Re: Request for Comments on the American Community Survey 5-Year Data Products Dear Ms. Schechter, On behalf of the Metropolitan Policy Program (Metro) of the Brookings Institution, I am pleased to respond to the notice in the March 6, 2009 Federal Register requesting comments regarding the Census Bureau’s proposal for American Community Survey (ACS) 5-Year data products. Metro promotes innovative solutions to help the nation’s metropolitan communities grow in more inclusive, competitive, and sustainable ways. From this perspective, we are quite excited about the forthcoming availability of annually updated ACS 5-year data products for small areas, replacing once-a-decade decennial long form data products. In several ways, the 5-year data products will be an important asset for facilitating the health and well-being of metropolitan America:

• The ACS 5-year products will allow the nation’s markets to work more efficiently. Businesses will use ACS 5-year data to identify markets, determine site location and product mix, and assess labor force availability.

• Local governments, metropolitan planning councils, and community-based and other local nonprofits will use ACS 5-year data to determine the need for, the design of, and the impacts of programs in realms such as transportation, health, education, workforce development, community and economic development, housing, and social services.

• Researchers will use the ACS 5-year data products to evaluate neighborhood demographic and socioeconomic trends.

We very much appreciate the hard work of the ACS Office in preparing a thoughtful, thorough 5-year data products proposal. Below, we comment on the periodicity of data release, rules for release of data, alternatives for releasing block group data, and plans for the types of products that will be released.

Periodicity of Data Release We enthusiastically agree with the Census Bureau’s plan to release 5-year ACS estimates annually, starting in 2010. As noted, the availability of annually updated 5-year data will be a substantial boon to public and private decision-making at all levels of geography. Rules Related to Disclosure Avoidance and Statistical Reliability The Census Bureau proposes that restrictions on the release of 5-year estimates be based solely on disclosure avoidance requirements, which are stricter than those used for Census 2000; it proposes to not apply statistical reliability standards to the 5-year data products. To set the context for our response, we disagree with the Census Bureau’s statement in the Federal Register notice that the ACS 5-year estimates will achieve the goal of providing data for small geographic areas that is similar to that of the long-form data from Census 2000. With a fixed sample size of three million households annually, the ACS 5-year sample is considerably smaller than the 1-in-6 household sample of Census 2000. The original ACS sample design was for three percent of households each year, a level that would have produced 5-year data for small geographic areas near the reliability and disclosure avoidance levels of Census 2000. However, the Census Bureau did not receive a budget for a sample similar to that of the long form; as a result, the 5-year data products cannot be as detailed for smaller geographic areas as they were in 2000. In light of the smaller sample size, we agree with the Census Bureau’s proposed stricter disclosure avoidance requirements. At the same time, we disagree with its proposal to not apply statistical reliability standards. To avoid misuse of the data, we believe that the Census should publish data only when they can be used reliably; we think the Census Bureau should maintain its reliability standards for the release of data products given the sample size. To aid user acceptance of this approach, we also recommend that the Census Bureau:

• openly acknowledge that, given the smaller sample size, some ACS 5-year products cannot meet some user needs for detailed census tract and block group data;

• make explicit its standards for statistical reliability and the reasons for those standards; • unambiguously state its collapsing rules; • work with data users, such as the transportation community, to develop summary

tables that, while less detailed than in 2000, will provide general information for small geographic areas; and

• enable data users to combine custom-selected small geographies into areas large enough to produce reliable estimates—we provide proposals to this end in the next section.

As noted, an underlying issue is that the Census Bureau needs sufficient budget to collect an annual ACS sample based on the original design of three percent of households. Data users have

a responsibility to help congressional appropriators understand the consequences of inadequate funding for the ACS. Block Group Level Geography – Alternatives for Release of Data Metro supports the Census Bureau’s plan to suppress detailed data at the block group level and to provide only a subset of the data products. While we have called for the Census Bureau to adhere to its reliability standards for its 5-year data products at all levels of geography, we recognize the importance of enabling data users to combine block groups to produce reliable data custom-fit to particular needs. Consequently, we strongly encourage the Census Bureau to identify one or more means by which data users can prepare such combinations that meet reliability standards. Such means might include a new Advanced Query System (AQS); Data Ferrett; and dedicated special tabulations staff at the Census Bureau. If the Census Bureau decides to make the full set of block group estimates available, we recommend that these data not be made available through American FactFinder. Rather, we suggest that block group data be made available through Data Ferrett or ftp download and only after users review plain English statement of caution and guidance on appropriate ways to combine data to achieve a reasonable level of reliability. Block groups are not the only geographies that will have unreliable data. Consequently, we suggest that the Census Bureau follow the above recommendations to support data user ability to safely work with unreliable estimates for census tracts and small political subdivisions. Types of Data Products We support the Census Bureau’s proposal to release 5-year PUMS files and 5-year ACS estimates in detailed tables in summary files, subject tables, data profiles, narrative profiles, selected population profiles, thematic maps, and geographic comparison tables. We agree that narrative profiles and selected population profiles are not needed for small geographic summary levels, such as block groups. While we assume the comparison profiles for 5-year products will resume in 2015, we would like to see an explicit statement to that effect. We recommend that ranking tables be a data product for the 5-year estimates at higher geographic levels (county, metropolitan, and state levels). Data users will rank areas, even if the Census Bureau does not. The advantage of the Census Bureau’s providing ranking tables is that the tables show the statistical significance of the comparisons, a factor reporters and other analysts often forget. We ask that the Census Bureau consider producing migration matrices aggregating 5-year estimates to provide state-to-state migration flows for selected selected demographic attributes (e.g., age, race-ethnicty, education, household type, education), and more limited matrices or

data showing inflow and outflow data for geographies of metropolitan areas, large cities and counties. The Census Bureau produced such matrices from the long form migration data after past decennial censuses. Thank you for the opportunity to respond the proposal for 5-year data products. We appreciate your office’s hard work, hope you find our comments and recommendations of value, and look forward to your response. Sincerely,

Andrew Reamer, Fellow Metropolitan Policy Program

<Elaine.Murakami@dot.gov>

04/20/2009 07:12 PM

To

<susan.schechter.bortner@census.gov> cc

<melissa.c.chiu@census.gov>, <edc@berwyned.com>, <pweinberger@aashto.org>, <kai.t.wu@census.gov>

Subject ACS 5-year Data products docket 090130099-9106-01

ACS 5-year Data products Docket 090130099-9106-01 Dear Susan: This is a small recommendation to the ACS 5-year data product list, in case Kai can’t find that it already exists. A table that breaks out Group Quarters population for Institutionalized and non-institutionalized similar to SF3 P9 or P11 would be a good addition to the ACS standard table set at the census tract level, and preferably at the block group level (omitting the proposed Rule 2). Thanks, Elaine Murakami FHWA Office of Planning

From: Murakami, Elaine <FHWA> Sent: Monday, April 20, 2009 4:00 PM To: 'kai.t.wu@census.gov' Cc: 'melissa.c.chiu@census.gov'; edc@berwyned.com; 'pweinberger@aashto.org' Subject: help with finding ACS tables with Group Quarters population (institutionalized and non-institutionalized) Dear Kai – I can’t find any tables in ACS where institutionalized and non-institutionalized Group Quarters population are broken out. For Census 2000, this breakout was part of tables on HOUSEHOLD TYPE, e.g. P9, and P11 in SF3.

I looked in the B11xxx series on “household type” but they don’t seem to be included. I can only find Group Quarters TOTAL POP (B26001). I guess I assumed this was available in the ACS standard table set, since it was in SF3 in Census 2000, so we did not include a similar table in CTPP for the 3-year table request. Please let me know if I have overlooked something! Elaine

April 21, 2009

To: Susan Schechter, ChiefAmerican Community Survey OfficeCensus Bureau

From: Patricia C. Becker, Executive DirectorSoutheast Michigan Census Council

Re: Response to Federal Register Notice on Five-Year ACS Products

Let me begin by congratulating you and your staff on the comprehensive outline of 5-YearData Products. It appears to be complete.

We have a number of concerns about the products, with a focus on the detailed tables.

1. As I have expressed on several occasions previously, the detailed tables need athorough review and revision. The second item in your list of restrictions, stating that“detailed tables with more than 100 cells cannot be released at the block group level”makes this even more imperative. The problem is not with the restriction itself, butwith the fact that many detailed tables far exceed 100 cells without providing any lesscomplicated way of presenting the same data. Specific concerns include:

a. Tables become larger because they present estimates by sex. While these areuseful in some instances, most users need a statistic such as the poverty rate orthe unemployment rate independent of sex. As a pragmatic matter, this hasmeant moving the “female” cells in the table up next to the “male” cells in thespreadsheet, and then adding male and female cells together to get a total forthe category of interest.

b. When age groups are also included in the table, the calculations become evenmore complicated. The classic example is B23001, in which almost tortuousmanipulations of the excel rows are necessary to calculate a simple labor forceparticipation rate or unemployment rate for a given geographic area.

c. The “C” tables were designed to eliminate some of the cross-tabulations inorder to avoid data suppression in the one-year and three-year products.Sometimes this has meant losing the data altogether, such as in a table which

28300 Franklin Road • Southfield, MI 48034 • (248) 354-6520Fax (248) 354-6645 • <info@semcc.org> • <www.semcc.org>

Response to Federal Register Notice on 5-Year ACS Products Page 2

includes all possible languages, and suppression eliminates the data on Spanishwhich, if the other languages were not included, would not be suppressed.

More examples can be found in the paper I presented, in January, 2007, at the AppliedDemography Conference. I cannot emphasize strongly enough that if the detailed tablesare not reviewed and revised, with the input of experienced users from outside the CensusBureau, these tables will continue to cause massive problems for users of ACS data.

2. In the Notice, you request feedback on specific issues. Our response follows:

a. Block Group Level Geography. We strongly support alternative disseminationof block group data. This data set should not be on American FactFinder. Instead,it should be available in a download area and accompanied by written caveats thatthe data should be used only in aggregate format.

b. Types of Data Products. The plan is very generous in terms of the data productsthat will be available. We have no problem with it.

c. Restrictions Required for Disclosure Avoidance or Statistical Reliability. Wehave no problem with items 1, 3, 4, and 5 on this list. The concern with item 2 isdiscussed above – it lies not in the restriction, but in the need to redesign thedetailed tables, as a product, so that the restriction will not interfere with whatdata users need. We will refrain from commenting on items 6 and 7, leaving thatto the transportation planning community; we support their concerns.

d. Periodicity of Data Release. We certainly have no problem with the annualrelease of 5-year estimates; it has been the expectation from the beginning of ACSplanning. We would be most interested in participating in any discussions thatinvolved proposed changes to that plan.

3. American FactFinder. We know that a new version of AFF is scheduled for release in2011, but have no details on what is planned. We are concerned that the user communityhas not been more involved in this process; the questionnaire that was circulated a year ortwo ago was insufficient. It is important for everyone to understand that, because AFF isthe primary vehicle for access to ACS data, its problems are ACS’ problems. Somespecific concerns include:

a. Aggregation capability. Especially with the advent of tract-level data, users willincreasingly want to aggregate groups of geographic areas to user-defined areas. In large cities, these are usually tracts. In strong MCD states, such as Michigan,they are also often county subdivisions. Effective use of ACS data for these user-defined areas means that users need to have margins of error recalculated, on thefly, in the AFF software, so that they may know the statistical reliability of the

Response to Federal Register Notice on 5-Year ACS Products Page 3

data for the aggregated geography. Is this part of the AFF redesign?

b. AFF includes a provision for saving and retrieving queries, but makes it difficultto name the query or to designate where it should be located on the user’s harddrive. This should not be difficult to fix. Will it be?

c. AFF often forces re-selection of geography when switching between variousforms of data products, such as detailed tables and data profiles. This should befixed.

I am certain that a poll of experienced AFF/ACS users would identify many other suchproblems. If ACS is to be successful as the major source of demographic and socio-economic information for the nation, it needs to work more interactively with users tomake sure that they can get, reasonably easily, the data they need.

4. Census Tract Delineation. I am certain that the Census Bureau has given no formalthought to the question of how often census tract delineation should take place. Thetradition of doing so every ten years has been part of the decennial cycle. With the adventof annual ACS data at the tract level, this issue needs to be revisited. Offhand, what maymake the most sense is a 5 year revision schedule, coinciding with 5-year revision ofmetropolitan areas.

We remain very concerned that the 2011 ACS release is going to be on “old” – 2000 –tracts while the PL file, coming less than two months later, will include data for the new,2010, tracts. Presumably the 2012 ACS release (for 2006-10 data collection) will also beon new tracts. This is bound to cause user confusion. We will “handle” it here insoutheast Michigan, but it will be a concern nationwide.

ICHlln

Wichita-Sedgwick County Metropolitan Area Planning Department

April 17, 2009

Susan Schechter, ChiefAmerican Community Survey OfficeRooni 3K276, Mail Stop 7500Washington, DC 20233-7500

Re: The Census Bureau's Proposed Changes for American Community Survey

Dear Ms. Schechter,

The proposed changes in the Census Bureau's Proposal for American Community Survey (ACS)Five-Year Data Products couldaffec;t many el~ment~ of publjc planning and a myriad of otherpublic and social,servic;e efforts. I.eurge yo:u rto\proceed ..with caution in implementing thesechanges.

It .appears to us that thesecpange,S,. wo:uld, seyerely compromise meaningful assessments forneighborhood planning efforts.c.e.nsus data 'has ,\lways be,en provided at geographical levelsappropriate., for' this type ofplaeJ;lI.ling. WWGb. contributes significantly" to neighborhood

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improvements in large urban areas such as Wichita. We also fear that many small communitieswould not be able to get meani!lgfu14~ta rel€;jvClI;tt,to their needs.

For transportation planning purposes we use economic, migration and immigration data at theTraffic Analysis Zone leveL It· appears that the proposed changes would make it difficult orimpossible to obtain the nec~ssary data at a meaningful geographic leveL Unless federaltransportation planning mandates are changed, we fear that it will not be possible to meet themany requirements that maJ<.~our locaUurisdic!ti~:ms eligible for federal transportation funds.

Environmental justice reviews, for tr.ansportation and.6ther projects also could become next toimpossible to do in any meaningfiIl, waY,,Ethnic and,socio-economic distinctions withincommunities are often relatively finely grainec,l;geographically. '

With this proposed action the Census Bureau would effectively eliminate the usefulness of whatused to be the long form·and the Census Transporta,tion Pimming Package would no 10lfger haveany credibility. Theproposed changes are, inJIlYHpinion,a st~p backwards.

City Hall • 10th Floor • 455 North Main • Wichita, Kansas 67202-1688

1'316.268.4421 .F,316.268.4390~ ; _.- . i

www.wichita.gov

Again, I urge you to proceed with caution and to expand the Census Bureau's efforts to informthe public and to extend the comment period.

WICHITA AREA METROPOIJTAN PLANNING ORGANIZATION

April 16, 2009

Susan Schechter, ChiefAmerican Community Survey OfficeRoom 3K276, Mail Stop 7500Washington DC 20233-7500

Dear Ms. Schechter:

The Wichita Area Metropolitan Planning Organization (WAMPO) is the metropolitan planningorganization (MPO) for the Wichita Kansas metropolitan area. WAMPO is comprised of 21 citiesand 3 counties with over half a million population. WAMPO relies on relatively small geographiclevel demographic and related data from the Census Bureau in developing the manytransportation programs and plans addressing growth in the region. We are very interested inthe transition that the Census Bureau istt'lakingfrom the census long-form sample to theAmerican Community Survey (ACS).Howeverj we arevery concerlled with the level of datadetail that will be availaple thro\-,gh the ACS, ~s described in the March 6,2009 Federal Register.

According to p~iorinformation8pthe ACStbatwe haves~en froln the. CensusBureau itself andfrom other fede~alagencies~'we'have been ledto befre~e that the data!available 'from the ACSwould be at the "county, city, and neighborhood!' level/and at the "detailed long-form level ofgeographic d~tail." Based on statements such as th~se, we have been anticipating ACS datat?1bulations that would provide as much d~taiiaspri(Jr Census products. However, theit;lformation discussed in the March 6, 2009 Feder~l Register notice, and particularly therestrictions on the release of data to meet disclosure requirements, will seriously impact theamount of data actually available for smaller geographic area analysis.

The limitation in small area dati;:lyvill make it much more difficult to address significant issues, ;

that are important for the cour;1trif;s' future progress. It will also constrain decisions that mustbe made at a local level. ltis ,vital F~~t ;WormatioQ be provided at a relatively small geographiclevel as the proposed chall~es" as w~ ~nd~rstandthem, will impact:

., ,.'.' . ' .. : ."!. .'

• Metropolitan'Planning Organization;Fecileral Legislation Compliance-,

o Travel D~rnand 1Vi0c.iels~r~integr1/ to the developmenfofpractical p'rojectprog~ams, the reductio~ in information will dramatically 'limit the usefulness of theinformation t,hese models provide.

o MP(i)s'abilitv to, efficiently produce accurate plans and programs that effectivelyaddress long.Jand short"range issues require precise and complete data.

1 OF" FLOOR· 4g5N, M~I\-.l • W,ICI-IITA KS • 67202-1688

P HO I:;J.E: (316) 268 - 4 3 ,91 • FAX:, ( 3 1 6) 268 - 4 3 9 a

-2- April 16, 2009

.. Land Use - to effectively address land use impacts on transportation, planners musthave access to relatively small geographic level data that makes it possible to fullyevaluate the relationship between land use and demographic patterns andtransportation choices.

.. Social Equity - to effectively address social equity, planners much understand thecomposition of the population in terms of disabilities or other mobility impairments,transit-dependent populations, households receiving temporary assistance for needyfamilies (TANF), limited English proficiency, and environmental justice status (lowincomes and minority population concentrations) and be able to relate those individualsand households to job opportunities, job access and reverse commute needs at a smallgeographic scale. Reports, plans, and programs would become next to impossible to doin any meaningful way.

e Effective Transportation - in an era of decreasing transportation funding, performance­based planning takes on greater urgency. To ensure that limited transportationresources are deployed as effectively as possible to support the nation's economicactivity, planners must have access to data that supports detailed analysis of a range oftransportation options in the context of actual traveler behavior at a relatively smallgeographic level.

We are concerned that the proposed rules as detailed within the March 6, 2009 Federal Registerwill clearly and adversely affect the ability of our regional planning agency to respond to local,regional, state, and national goals and objectives. We would encourage the Census Bureau todevelop and consider additional, creative solutions that would provide data at the level of detailto support responsible planning and decision-making. Understandably some data may not besuitable for the dissemination to the general public; however, with caveats on confidentiality,this information should continue to be provided to states and MPO's. Only with this informationwill states and MPO's be able to continue to make efficient and effective decisions.

Please consider extending the comment period and using the national agencies available such asASSHTO and the Association of Metropolitan Planning Organizations (AM PO) to provide moreinsight into the ramifications of this decision.

Sincerely,I

~rfNancy Ha/~X, AICP .__._.~._Transportation Planning Manager

cc: WAMPO Transportation Policy Body

p- _. _._----------------,--Kansas Association of MetropolitanPlanning Organizations

Gl Social Equity - to effectively address social equity, planners must understand thecomposition of the population in terms of disabilities or other mobility impairments,transit-dependent populations, households receiving temporary assistance for needyfamilies (TANF), limited English proficiency, and environmental justice status (low incomesand minority population concentrations) and be able to relate those individuals andhouseholds to job opportunities, and job access and reverse commute needs at a smallgeographic scale. Reports, plans, and programs would become next to impossible to do inany meaningful way.

e Effective Transportation - in an era of decreasing transportation funding, performance­based planning takes on greater urgency. To ensure that limited transportation resourcesare deployed as effectively as possible to support the nation's economic activity, plannersmust have access to data that supports detailed analysis of a range of transportationoptions in the context of actual traveler behavior at a relatively small geographic level.

KAMPO is concerned that the proposed rules as detailed within the March 6, 2009 FederalRegister will clearly and adversely affect the ability of our regional planning agencies to respondto local, regional, state, and national goals and objectives. KAMPO encourages the Census Bureauto consider additional, creative solutions that would provide data at the level of detail to supportresponsible planning and decision-making. Understandably some data may not be suitable forthe dissemination to the general public; however, with caveats on confidentiality, this informationshould continue to be provided to states and MPO's. Only with this information will states andMPO's be able to continue to make efficient and effective decisions.

Please consider extending the comment period and using the national agencies available such asNational Association of Regional Councils (NARC) and the Association of Metropolitan PlanningOrganizations (AM PO) to provide more insight into the ramifications of this decision.

Kansas Association of Metropolitan Planning OrganizationsLawrence-Douglas County Metropolitan Planning OrganizationMid-America Regional CouncilSt. Joseph Metropolitan Planning OrganizationMetropolitan Topeka Planning OrganizationWichita Area Metropolitan Planning Organization

cc: Governor of KansasKDOT SecretaryKansas Secretary of StateUS Senators from KansasUS Congressmen from KansasFTA Region 7 AdministratorFHWA Kansas Division Administrator

l.awrence·Douglas County MPOP.O. Box 708lawrence, 1<8 660441785) 832·3150

Mid·America Regional G~llllcil

60ll Broadway, Suite 200Kansas City, MO 64105(8lel 474·4240

St. Joseph rv!PO110() fmdmick ,,,venueSt. Joseph, 64tl()1(8Hl127Hi324

Metropolitan Topeka Planning Organization620 SE Madison, 3rd FloorTopeka, KS 666071785) 368·3728

Wichita Area MPO455 North Main StreetWichita. KS 67202(316) 268·4391

P.O. Box 200908, Anchorage, AK 99520-0908(907) 279-2511 0 Fax: (907) 278-2309

www.ruralcap.com

Rural Alaska Commun

April 17, 2009

Susan SchechterChief, American Community Survey OfficeU.S. Census Bureau4600 Silver Hill Road, Room 3K276Mail Stop 7500Washington, D.C. 20233-7500

Action ram, Inc.

RE: Comments on American Community Survey 5-Year Data Products/Federal RegisterDocket Number 090130099-9106-01

Dear Ms. Schechter:

I want to thank you for the attention you have given in the past year to issues pertaining to theimplementation of the American Community Survey in rural Alaska. We have appreciated theCensus Bureau's wilhngness to not only listen to our concems, but to participate in a field visithere to see first-hand the challenges of data collection in our rural villages.

We offer the following comments regarding the American Community Survey 5-Year DataProducts:

• We continue to have concems about the small sample sizes and availability and reliabilityof data at the block group level for areas in rural Alaska. We encourage the Bureau toexpand the sample size in sparsely-populated areas and small communities.

• There is concern that some geographic summary levels such as block groups will receiveonly a subset of the full set of data products.

• While we understand the logic of not preparing narrative profiles for block groups incities and larger communities, we believe that such a product would be of great value tosmall communities (for whom the block group is the level oflocal geography) who donot have access to this kind of information from other sources. We recommend that the'Bureau prepare narrative profiles for block groups in sparsely-populated areas

• Regarding the periodicity of data release, we support the U.S. Census' position that theone, three and five-year ACS estimates be released annually

While there is no question that geographic areas with populations greater than 65,000 willbenefit from the release of characteristic data on an annual basis, we will need to wait until 2010to make the same statement about Alaska's areas with limited populations.

Healthy People, Sustainable Communities, Vibrant Cultures

Enclosed is a copy of RurAL CAP's 2008 Annual Report. Please note that the photo on pageseven highlights the U.S. Census Bureau's 2008 visit to Atmautluak, a remote village in theYukon-Kuskokwim Region. The photo was taken by your very own Tim Olsen, AssistantDivision Chief, Field Division.

We look forward to a continued discussion about how the ACS will help provide criticalinformation about Alaska's people.

IiJvCryrulY Y~:,.rs,

C~y,· .. .,/ . VI.

" "- "-----..Mitzi C. Barker, FAICPDirector, Rural Housing & Planning Division

295 North Jimmy Doolittle Road' Salt Lake City, Utah 84116 • www.wfrc.orgPhone Salt Lake: 801.363.4250 • Fax: 801.363.4230 • Phone Ogden: 801. 773.5559

Dear Ms. Schechter:

Sincerely,

Thank you for your consideration.

Charles W. Chappell, P.E.Executive Director.

Thank you for the opportunity to comment on the proposed release ofAmerican Community Survey 5-Year Data Products. With the continuedincreasing emphasis on quantitative analysis for national, state, and localpolicy decisions, we reject the proposal that "restrictions on the release of5-year estimates be based solely on disclosure avoidance requirements."Restriction #7 (affecting means of transportation) is particularly hard towork with for metropolitan planning organizations and other agenciesresponsible for transportation planning and operations. The ability tocross tabulate transportation mode with other variables at a smallgeographic level is essential to effective planning for transportationmode$, especially to plan alternatives to the single occupant vehicle.

Restriction #7 reduces our ability to support the Administration's emphasison improving public transportation. Here are two of several potential ideasto facilitate cross tabulation of transportation mode: 1) Focus resources,perhaps with partners, toward increasing sample size; 2) Use appropriatedata synthesis techniques. We need your help in providing essential datafor the federally mandated transportation planning process.

Susan Schechter, ChiefAmerican Community Survey OfficeRoom 3K276, Mail Stop 7500Washington, DC 20233-7500

April 20, 2009

John Petroff, Jr.ChairmanMayor, West Point

Michael H. JensenVice-ChairmanCouncilman, Salt Lake County

Byron AndersonMayor, Grantsville

Ken BischoffCommissioner, Weber County

J. Bruce BurrowsMayor, Riverdale

Carlton ChristensenCouncilman, Salt Lake City

Peter CorroonMayor, Salt Lake County

J. Lynn CraneMayor, Herriman

Craig L. DeardenCommissioner, Weber County

Tom DolanMayor, Sandy

Matthew R. GodfreyMayor, Ogden

Joe L. JohnsonMayor, Bountiful

Bret MillburnCommissioner, Davis County

Kent MoneyMayor, South Jordan

Dennis NordfeltMayor, West Valley City

Ronald G. RussellMayor, Centerville

Bruce SandersCouncilman, Morgan County

JoAnn B. SeghiniMayor, Midvale

Senator Carlene M. WalkerUtah State Senate

Representative Todd KiserUtah House of Representatives

Louenda DownsUtah Association of Counties

Russ WallUtah League of Cities &Towns

John NjordUtah Department ofTransportation

John InglishUtah Transit Authority

Robert GrowEnvision Utah

Davis • Morgan • Salt l.ake • Tooele • Weber

DISTILLERS OF OFFICIAL DATA ® SINCE 1974

This is in response to the notice in the FR vol. 74, no. 43 of March 6, 2009. My apologies for being late on this. I was very busy on a months-long project and only heard about this from the handout at your presentation at the NCSL meeting. I understand this will, therefore, not be a part of the official record. By way of introduction, my background includes two decades of dealing with census data releases, beginning with the summary tape files from the 1980 Census and continuing on with the annual releases of population estimates as well as other programs of the Bureau of the Census. My skills involve database programming and my mission is to process the raw census data into formats that both I can use for my own publications as well as distilling them down to useful formats for researchers. The data for the past three decennials have used, more or less, the same general data structure and one that, in my opinion, still works in today’s computing environment. Even though the hardware is greatly different than that of previous decades, much of the software is still based upon legacy concepts. Inasmuch as I am more of an analyst than a programmer, I spend my time trying to work with the data rather than developing it into the fashion of the day. As such, I find the familiar format useful and workable, and efficient from a time perspective. However, I understand the degree to which others have adapted to newer technologies and how many users only have any actual contact with raw data via the census website at American Fact Finder. For those of us who still download the entire datasets and convert them into a format with which we are familiar, I offer the following comments.

POLIDATA® Political Data Analysis DATABASE DEVELOPMENT, ANALYSIS AND PUBLICATION;

POLITICAL AND CENSUS DATA; LITIGATION SUPPORT

CLARK BENSEN POLIDATA· 1303 HAYWARD RD, P.O. BOX 530· CORINTH, VT 05039

Tel: 703-690-4066 · Fax: 202-318-0793 · email: clark@polidata.org PUBLISHER OF THE POLIDATA ® DEMOGRAPHIC AND POLITICAL GUIDES AND ATLASES

Susan Schechter, Chief American Community Survey Office Room 3K276, Mail Stop 7500 Washington, DC 20233-7500

Wednesday, May 06, 2009

File: FR_ACS_5YR

Re: Federal Register Request for Comments: ACS 5-year Data Release

ACS Comments on 5-year Data Products, Page 2

1) Distribution: FTP is the most efficient and the bundling of many data files into as few zip files as possible works well;

2) Folders: it would be useful if the user, when they UNZIP the files, did not have multiple levels of folders on the user’s computer, though this is something that can be worked around by knowledgeable users;

3) Data Format: .dbfs, though a legacy format, are useful because they can a) be opened by most software to at least view a portion of the file and b) conserve substantial disk space; they have an established data structure as to the field type and length though they have a limitation or two: namely 10 character field names and a maximum number of fields in a record (254) and a maximum of record length (but this should not be a problem given the size of the 254 fields); nevertheless, this format worked fine for previous STFs and appears to have worked fine with the 2007-3 Year release also, assuming the user keeps three separate data files for each table; whether or not the data files are released in this fashion, it would be useful to have all data shells available in .dbf format;

4) LOGRECNO: this link seems to work fine until the national compilations of datasets are brought together; for the 2000 Summary Files my recollection is that the records were merely brought together and thus the LOGRECNO was no longer unique within the file;

5) SUMLEVEL: a few basic fields were renamed for the ACS files but generally most are the same or discernible; I assume this was for convenience or standardization and that this does not indicate any actual change in the concept; nevertheless, even minor changes such as SUMLEV to SUMLEVEL will require changes in code from previous census reviews and some basic review would not need any change other than this, but this is a minor point;

6) Comparability with previous census data: I understand that the ACS data are from a different source and they are all sample data but some variables do not appear to be evident in the ACS data. E.g., URBAN vs. RURAL: which was in the census 2000 geographic files and now appears to be in the GEOCOMP records: aside from the wholesale change in METRO/MICRO schema, there are some geographic factors which accompanied the 2000 Summary Files which do not appear in the ASC, e.g., Urban/Rural and Area Size from which one can estimate population density;

7) Comparability with other census data: In a similar fashion, there are factors which are available in the PL94-171 Reapportionment files which cannot be replicated with the ACS. The PL94 files have Race and Race/Spanish Origin breaks which allow for analysis based upon a Statistically Additive/Mutually Exclusive (SAME) structure. The detailed tables in the ACS do not allow for such comparisons for all population subgroups and not for both Population and Voting Age Population.

ACS Comments on 5-year Data Products, Page 3

8) Citizenship: Likewise, another factor of interest to political data users is the citizenship data as this relates directly to voter registration and turnout rates. Following 2000 there was a special tabulation which contained much of this information but again, comparability will be an issue. I wonder if there is to be a special tabulation program for the ACS whereby the data specifically useful for political researchers can be accommodated.

9) Collapsed tables and Suppression: In my recent use of the ACS files, once I became acclimated to the new data structure and was able to actually see the data, I encountered a problem with the distinction between the “B” and “C” tables (why is that there are no “A” tables?). My problem was that when I used the “B” detailed tables, I encountered suppression on the Hispanic numbers at the high geographic level of the Congressional District. This was an issue because of two misconceptions on my part: a) that there could be no suppression of any factor at such a high level of geography and b) that the Hispanic summary, unlike the Race summary, was not a specific response to the Hispanic question but was merely the combination of all the Hispanic subgroups. The problem here was that there were districts that are overwhelmingly Hispanic for which no data were available from the “B” tables, and indicated as such in the AFF tables also. Clearly others will fall into this same trap and I suggest a) on the AFF site, the creation of a link to collapsed data that might eliminate the suppression problem and b) a clear distinction of the reason for the “B” vs. “C” tables as well as c) a review of the suppression criteria for high levels of geography. This same problem showed up in a few other factors that I was using for my data review, largely due to the nature of the subgroups.

10) Suppression Language: Anent this discussion, the following line shows up if a user clicks on the Survey Methodology on the AFF site: “To maintain confidentiality, the Census Bureau applies statistical procedures that introduce some uncertainty into data for geographic areas with small population groups.” If a congressional district can be such a ‘geographic area’ for which suppression applies for ‘small population groups’ this sentence should be changed as it appears that it would apply to every geographic area. Suggestion: To maintain confidentiality, the Census Bureau applies statistical procedures that introduce some uncertainty into data for <<tables that reflect data for>> small population groups, <<regardless of the level of geography>>. And then add: For many tables, there is a related, collapsed, version of the detailed table that may provide non-suppressed information by combining the responses for the small population groups.

11) AFF Links: It would be quite helpful for those of us who use the AFF site frequently to be able to replicate a search a) specifically or b) generically. I realize having a user account might be too much to request but if there was some way one could either specifically repeat a search from an earlier time or modify it so

ACS Comments on 5-year Data Products, Page 4

that it was for the same table but from the 1-year versus 3-year, or for one state versus another, this would be expeditious. I use the site to review what data I would like to include as well as a check for the conversion I have made. It is also helpful for directing others to the information. It appears that the replication might be solved by the URL which appears to now be transportable or permanent. It would be even more helpful if this could be somehow be made generic so that one or two factors could be modified but for now at least one can reenter the system via the URL and that is important.

12) AFF Sequence: Another minor point but it would be quite helpful to add a row or column indication on the tables generated by the AFF site.

13) Color coding: Also, I would find it useful to add color coding somehow so that there is a clear differentiation between the 1-year, 3-year, and 5-year products, perhaps merely with a color logo that would thus also be distinguishable when reports are printed on monochrome printers.

Again, sorry for the delay, although some of these were presented by me at a recent Census Advisory Committee meeting. Likewise, sorry for the tedious aspect of some suggestions but considering that we will be dealing with this information every year now it seems appropriate to make suggestions on how to eliminate confusion. As a final thought, I would reiterate the often heard notion that confusion will reign when the December 2010 release of the 2005-2009 5-year data ‘hits the streets’. Thank you for the opportunity to comment on the ACS data products.